Privacy Policy
At Luminosa Connect, relationships, trust and confidentiality are central to the way we work. This Privacy Policy explains how we collect, use, hold, disclose and protect personal information, and the choices you have about your information.
Luminosa Connect is committed to handling personal information responsibly and in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs) where they apply to us. We also use the APPs as our privacy standard for the way we operate.
This policy applies to candidates and prospective candidates, clients and prospective clients, referees, business contacts, website users and other people whose personal information we handle.
1. Personal information and sensitive information
Personal information is information or an opinion about an identified individual, or an individual who is reasonably identifiable. It can include your name, contact details, employment history, qualifications, professional experience, remuneration information, career preferences and correspondence with us.
Some personal information is treated as sensitive information under Australian privacy law. This can include information about health, racial or ethnic origin, political opinions, religious beliefs, sexual orientation, professional or trade association membership, criminal records and certain biometric information.
We only seek sensitive information where it is genuinely relevant to our work and, where required, with your consent or as otherwise permitted by law.
2. Information we may collect
Candidates and prospective candidates
Depending on our relationship with you, we may collect:
• your name and contact details;
• your CV, résumé or professional profile;
• employment history, experience, skills and areas of expertise;
• education, qualifications, licences and professional registrations;
• current or previous employment information;
• career interests, goals and preferences;
• preferred location and working arrangements;
• salary or remuneration expectations, availability and notice periods;
• information about work rights relevant to a particular opportunity;
• information you provide during meetings, calls, interviews or correspondence with us;
• publicly available professional information, such as a LinkedIn profile or professional biography;
• referee details and information provided by authorised referees;
• information relevant to qualification, registration or other authorised checks; and
• other information reasonably necessary to assess or assist with an employment or professional opportunity.
For particular roles, we may also need to handle information relating to police checks, working-with-children checks, health or fitness assessments, visas, licences, professional registration or other background checks. We will only request this information where it is genuinely relevant, lawfully requested by a prospective employer or required by law.
We do not routinely ask candidates to provide information about matters such as age, marital or family status, pregnancy, religion, sexual orientation, gender identity, disability or health history unless it is relevant and lawful to collect for a specific purpose.
Clients and prospective clients
• names and business contact details;
• job titles and organisations;
• information about recruitment requirements, searches and vacancies;
• communications with us;
• contractual and billing information; and
• other information reasonably required to establish and manage our business relationship.
Referees
• your name and contact details;
• your position and organisation;
• your professional relationship with a candidate; and
• information or opinions you provide as part of an authorised reference process.
Website users and other contacts
When you visit our website or communicate with us, we may collect information such as:
• information submitted through enquiry, registration or contact forms;
• email addresses and other contact information;
• IP address and basic device or browser information;
• website usage information; and
• information collected through cookies or similar technologies.
3. How we collect personal information
Where practical, we collect personal information directly from you. This may occur when you:
• register with Luminosa Connect or provide us with your CV;
• speak or meet with us;
• apply for or enquire about an opportunity;
• communicate with us by email, telephone, video meeting, social media or another channel;
• complete an online form or provide information through our website; or
• otherwise engage with our services.
We may also collect personal information from other sources where appropriate and lawful, including professional networking platforms such as LinkedIn, publicly available professional information, referrals or introductions, clients and prospective employers, referees you have authorised us to contact, professional registration or verification sources and service providers carrying out authorised checks.
If we obtain personal information about you from another source and retain it, we will take reasonable steps where required to make you aware of the collection and how we intend to use the information. If we receive personal information we did not request, we will consider whether we could lawfully have collected it. If it is not required and there is no lawful reason to retain it, we will take reasonable steps to delete or de-identify it.
4. Why we collect and use personal information
We collect, hold and use personal information primarily so that we can provide recruitment, executive search, career-related and associated business services.
For candidates, this may include:
• understanding your professional experience, career interests and goals;
• identifying and discussing opportunities that may be relevant to you;
• assessing your suitability against the requirements of a role;
• coordinating recruitment and interview processes;
• communicating with prospective employers where you have agreed to be represented;
• arranging authorised reference or verification checks;
• keeping in contact about relevant future opportunities; and
• maintaining appropriate recruitment records.
For clients, this may include:
• understanding recruitment and workforce requirements;
• undertaking searches and recruitment assignments;
• presenting suitable candidates;
• managing our business relationship;
• administering agreements and invoicing; and
• communicating about our services.
We may also use personal information for reasonable business purposes such as maintaining records, improving our services, managing and protecting our systems, responding to questions or complaints, obtaining professional advice and complying with legal or regulatory obligations. We will not use personal information for an unrelated purpose unless we have an appropriate legal basis to do so.
5. Candidate representation and CVs
We take candidate confidentiality seriously.
Registering with Luminosa Connect does not give us blanket permission to circulate your CV or identity to employers.
As our usual practice, we will discuss a particular opportunity with you and obtain your agreement before personally identifying or formally presenting you to a prospective employer for that opportunity. Once you have agreed that we may represent you, we may provide that prospective employer with information reasonably relevant to assessing you for the opportunity.
We ask candidates to tell us if they are already being represented for the same opportunity or have already made a direct application so that duplicate submissions can be avoided.
6. References, verification and work rights
We will not contact your current employer or another referee without your permission or other lawful authority.
Where a reference, qualification, registration, work-rights or other background check is relevant, we will explain what is required and obtain any consent reasonably required before proceeding. Information obtained through checks will only be used for legitimate recruitment-related purposes and will be treated confidentially.
For some recruitment processes we may need to confirm that a candidate has appropriate rights to work in the relevant country. We will only collect or view identity, visa or work-right information where reasonably necessary. Where government-related identifiers appear on documents provided to us, we will not adopt those identifiers as our own internal identifier except where permitted by law.
7. Sensitive information and reasonable adjustments
We do not wish to collect sensitive personal information unless it is genuinely required.
If you tell us that you require an adjustment or support during a recruitment process, we will focus wherever possible on the adjustment or support you need rather than asking for unnecessary medical information.
Where sensitive information is reasonably necessary, we will obtain consent where required and restrict its use and disclosure to the purpose for which it was collected or as otherwise permitted by law.
8. Who we may disclose personal information to
Depending on the circumstances, we may disclose personal information to:
• prospective employers where a candidate has agreed to be represented;
• client organisations engaging our recruitment services;
• referees authorised by a candidate;
• professional registration, verification or background-check providers where relevant and authorised;
• technology providers that support our CRM, email, document storage, communications, website or business systems;
• accountants, insurers, lawyers and other professional advisers;
• contractors or service providers who assist us in operating Luminosa Connect;
• government bodies, regulators, courts or law-enforcement bodies where required or authorised by law; and
• another party where you have specifically consented to the disclosure.
We do not sell candidate databases or personal information to third parties.
9. Cloud services and overseas processing
Like most modern businesses, Luminosa Connect uses cloud-based technology and service providers to operate efficiently. These may include customer relationship management systems, email and communications platforms, cloud storage, website hosting, online forms and other business software.
Some providers may store, process, support or allow access to information from locations outside Australia, including the United States and other jurisdictions in which those providers or their approved service providers operate.
Where Australian privacy law applies to an overseas disclosure, we will take reasonable steps appropriate to the circumstances to ensure personal information is handled consistently with applicable Australian privacy requirements.
We also take reasonable steps to select reputable providers and consider their privacy and security arrangements.
Provider locations can change as technology infrastructure changes. Where practicable, more specific information about likely overseas locations will be provided in an applicable collection notice or on request.
10. How we protect and retain personal information
Security
We take reasonable technical and organisational measures to protect personal information from misuse, interference, loss, unauthorised access, unauthorised modification and unauthorised disclosure. Depending on the information and systems involved, these measures may include:
• reputable business-grade cloud and technology providers;
• password and authentication controls, including multi-factor authentication where available and appropriate;
• restricting access to people who need the information;
• device and software security;
• secure document handling;
• backups and recovery processes where appropriate;
• confidentiality and privacy procedures; and
• appropriate destruction or deletion practices.
No method of electronic transmission or storage is completely risk-free. We review reasonable safeguards appropriate to the size and nature of our business and the information we hold.
Retention
Recruitment relationships can continue over a number of years because a person who is not seeking a new opportunity today may wish to hear from us in the future. We therefore retain personal information while there is a reasonable recruitment, relationship-management, legal or business purpose for doing so.
We periodically review the information we hold. When personal information is no longer reasonably required and there is no legal obligation or other lawful reason to retain it, we will take reasonable steps to delete, securely destroy or de-identify it.
You can contact us at any time if you no longer wish Luminosa Connect to retain your details for future recruitment purposes. In some circumstances we may need to retain limited records, for example to comply with law, establish or defend legal rights or maintain records of previous recruitment transactions.
11. Accuracy, access and correction
We take reasonable steps to ensure personal information we use or disclose is accurate, current, complete and relevant. We also rely on you to tell us when important information changes.
You may request access to personal information Luminosa Connect holds about you, or ask us to correct information that is inaccurate, out of date, incomplete, irrelevant or misleading.
We may need to confirm your identity before providing access. We will respond within a reasonable period and will not ordinarily charge for making an access or correction request. There may be limited circumstances in which access may lawfully be refused. Where required, we will explain the reason and available complaint mechanisms.
12. Recruitment communications and marketing
If you register with Luminosa Connect or ask us to assist with your career, we may contact you about employment or career opportunities that we reasonably believe may be relevant to you. You can tell us at any time that you no longer wish to receive these communications.
We may separately invite you to receive Luminosa Connect news, insights, events or other marketing communications. Where required, these communications will only be sent with appropriate consent, will identify Luminosa Connect and will provide a simple way to unsubscribe.
Choosing not to receive general marketing communications will not prevent you from using our recruitment services.
13. Website, cookies and analytics
Our website may use cookies, analytics and similar technologies to help the website operate, understand how it is used and improve the user experience. These technologies may collect information such as IP address, browser type, device information, pages visited and approximate usage information.
You can usually control cookies through your browser settings and, where available, through website cookie settings.
Our website may contain links to third-party websites. Luminosa Connect is not responsible for the privacy practices of external websites, and we recommend reviewing their privacy policies separately.
14. Artificial intelligence and automated tools
Luminosa Connect may use technology-assisted or AI-enabled tools to support administrative tasks, information organisation, research, search and recruitment workflow.
We do not currently use automated decision-making to make final decisions about candidates without meaningful human involvement.
Candidate suitability, representation and recruitment decisions made by Luminosa Connect involve human judgement and oversight. When selecting and using AI-enabled or automated tools that involve personal information, we consider privacy, confidentiality and security requirements.
If our use of automated decision-making materially changes, we will update this Privacy Policy as required.
15. Data breaches
Luminosa Connect takes suspected privacy and data-security incidents seriously. If we become aware of a suspected data breach, we will assess the incident and take appropriate steps to contain and remediate it.
Where the Notifiable Data Breaches scheme under the Privacy Act applies and a breach is likely to result in serious harm, we will notify affected individuals and the Office of the Australian Information Commissioner (OAIC) as required by law.
16. Privacy questions and complaints
If you have a question, concern or complaint about how Luminosa Connect has handled your personal information, please contact us so that we have an opportunity to address it.
Privacy Contact
Luminosa Connect
Luminosa Global Pty Ltd
Email: nicola@luminosaconnect.com
Website: www.luminosaconnect.com
Please provide enough information for us to understand the issue. We will acknowledge and investigate legitimate privacy complaints and aim to respond within a reasonable period.
If your complaint relates to conduct governed by the Privacy Act and you are not satisfied with our response, you may be able to lodge a complaint with the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au.
17. Changes to this Privacy Policy
Privacy law, technology and our business systems can change. We may update this Privacy Policy from time to time so that it continues to accurately describe how Luminosa Connect handles personal information.
The current version will be published on our website and will show the date it was last updated. Where a change materially affects how we handle existing personal information, we will take reasonable steps to communicate the change where appropriate.